Record of Determination

Transport Scotland Trunk Road and Bus Operations

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DIRECTIVE 2011/92/EU as amended by DIRECTIVE 2014/52/EU

ROADS (SCOTLAND) ACT 1984 (as amended)

THE ROADS (SCOTLAND) ACT 1984 (ENVIRONMENTAL IMPACT ASSESSMENT) REGULATIONS 2017

RECORD OF DETERMINATION

Name of Project: A82 870 Ballachulish Location: Ballachulish, Loch Leven Bridge - Five-Year Marine Licence NN 05195 59797

Description of Project:

As part of the 4G NW contract with Transport Scotland for the management and maintenance of the Scottish trunk road network, BEAR Scotland (NW Unit) are responsible for maintenance and improvement works on the bridge. The Ballachulish Bridge is a two-lane steel truss road bridge that carries the A82 trunk road across Loch Leven as shown in Figure 1.

Figure 1: Ballachulish Bridge

The following maintenance works are proposed to be undertaken on the Ballachulish Bridge over the next five years:  Carriageway and footpath resurfacing  Bearing Replacement

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ENVIRONMENTAL IMPACTS AND PROPOSED MITIGATION: SUMMARY

Issue Baseline Conditions Impact Mitigation Air and Climate There are approximately eight residential properties During the construction phase air quality impacts are likely to stem  Plant, machinery and vehicles associated with the works will have engines switched off when not in north-east of the scheme within 200m and five from construction vehicles and plant on-site as well dust as a use in order to minimise emissions: residential properties witin 200m south of the scheme. result of maintenance activites., impacts on air quality are not anticipated to be significant, provided the the Site Environmental  Machinery and vehicles will have been serviced regularly; Management Plan (SEMP) is adhered to and mitigation is There is a small industrial estate with four commercial  A traffic management plan will be in place to control the length of time that traffic needs to idle; properties north-east of the scheme within 200m of followed. the scheme.  Large material stockpiles will be avoided and drop heights will be minimised to reduce dust; and Due to the short-term nature of the works, GHG emissions from  In the event of prolonged periods of dry conditions, work areas will will be dampened down where the scheme are not considered to be significant. appropriate. The contractor will will implement this measure with care to aboid mobilisation of dust that would impact the local air quality. The proposed work is not expected to affect air quality during the

operational stage, as it will not result in change in traffic levels or dynamics.

Cultural Heritage and Material Assets The Ballachulish Hotel is a category B listed building, The proposed works will be confined to the existing footprint of the . Mitigation as detailed in the Noise and Landscape sections will be adhered to. located approximately 80m south-west of the scheme. bridge structure and access to the Ballachulish Hotel grounds will There are three scheduled monuments within the be prohibited. Significant impacts on cultural heritage and material vicinity of the scheme. The Rubha Mor Cairn is within assets are not anticipated during construction or operation. 200m to the north-west; the Ballachulish Prehistoric Ritual Site is within 200m to the north-east; and the Ballachulish Home Farm Burial Mound is approximately 250m south-west of the scheme. Biodiversity The following good practice measures will be adhered to during the maintenance works: Onich to North Ballachulish Woods Special Area of Without mitigation, there is the potential to disturb birds and otters. Conservation (SAC) is located 1km north of the Activities that have the potential to cause disturbance can include scheme. the use of machinery, vehicles and plant, floodlighting, removal of  Implementation of debris netting, protective shelters, containment; and sumps; vegetation and increased human activity. The Glen Etive and Glen Fyne SPA is 900m to the  Ensure that all milling works are carried out during suitable periods of weather; south-east at its closest location. The SPA is Given the localised and temporary nature of the works, and the designated for breeding golden eagle. The nesting, absence of a reasonable pathway to affect the features and the  Remove debris from gullies and drains using vacuum truck; breeding and optimal foraging habitat for the golden adherence to mitigation measures and the SEMP, significant eagle are found away from roads and on higher impacts are not anticipated to the Onich to North Ballachulish  Double bag guano; elevations. Woods and Shore SSSI or SAC; the Glen Etive and Glen Fyne  Contain the underbidge working platform with either debris netting or thickened sheets (if hydro- SPA or St John’s Church SSSI as a result of the proposed demolition); St John's Church SSSI is located 1.5km south-east of maintenance works as confirmed following consultation win SNH the scheme and is designated for its geology. in April 2018 (Shown in Appendix F).  Layering floor of working platform to prevent any material or water going through (if hydro-demolition);

Terrestrial and aquatic ecology sruveys ecological There were PMFs recorded in the vicinity of the scheme as noted  Remove all waste concrete from site; habitat field surveys were undertaken within the study in the ‘Description of the Local Environment’ section. There is Adherence to relevant PPGs and GPPs including GPP5 (works and maintenance in or near water); area in 2016 by BEAR Scotland Environmental team potential for negative impacts on these species in the absence of  mitigation measures. Given the nature of the works and adherence and follow-up surveys were undertaken in March  Edge protection and toerails to prevent any materials dropping into water. 2018. to the mitigation measures as set out in the ‘Water’ and ‘Waste Material and Use of Natural Resources’ sections, significant  Rock armour will be washed and cleaned prior to placement. impacts upon biodiversity are not anticipated as a result of the The surveys recorded the presence of otter spraints maintenance works. on the shoreline to the south-east of the bridge. An organisational otter licence (Number 118944 valid from 10 April 2018) obtained by BEAR Scotland NW Unit There is the potential of impact to otters using the area during the and Species Protection Plan will be followed during the main works until 31 December 2019 to reduce The 2018 surveys identified breeding bird habitat in disturbance to otter; these are included as Appendix F. The contractor must obtain a copy of an updated or the woodland to the south of the bridge but evidence construction phase as a result of pollution and disturbance caused extended organisational licence, or obtain a project-specific one if the organisational one is not updated, for of prior human disturbance was observed. by the presence of plant and machinery, vehicles, floodlighting and increased human activity. This could disruption to normal any works affecting otters after 31 December 2019. Conditions outlined in the licence will be followed by way of foraging routes. A well-used otter spraint was recorded on the Potential roosting and foraging opportunities for bats mitigation. shoreline to the south-east of the bridge during the site walkover. were identified in the woodland to the south of the Therefore, a disturbance licence will be required. bridge. No suitable features to support bats were Otter monitoring surveys will be required if works are conducted that could impact any potential otter couch. identified on the bridge superstructure. Cameras will be deployed for a period of 14 days to monitor the activity of otter. The requirement of these Should any discharge into the marine environment be intended The following PMFs have been recorded in the then a CAR licence will be obtained. Adherence to the good surveys will be dependent on the maintenance work in question and should be taken under the advisement of

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vicinity of the Ballachulish Bridge: practice and management measures, as listed here and in the the BEAR environmental team. Water section in this table, will result in no significant effects on . Kelp and seaweed communities on sublittoral the benthic receptors beneath and adjacent to the bridge, The following mitigation is also proposed: sediment (under the bridge); including PMFs during the construction and operational phases. . Tide-swept algal communities (Laminaria  Setting up of an exclusion zone of 30m around any potential otter couch; hyperborea on tide-swept infralittoral mixed substrata) on the east and west sides of the  Site supervisor will brief all persons on site as part of the induction process to ensure everyone is bridge (approximately 200m away) and further aware of the presence of otter, the mitigation measures and their legal obligations; upstream in Loch Leven;  The Otter Toolbox talk will be included in the Site Environmental Management Plan (SEMP) and . Horse mussel beds approximately 400m east of the bridge; and delivered to site personnel prior to commencement of works; . Sea loch eggwrack beds in Bishops Bay,  A “soft start” will be implemented on the works each day. This will involve checking under/around approximately 800m north-east of the bridge. vehicles and the immediate work area and then switching on vehicles prior to works commencing, with A small watercourse flows down the shore at NN the aim of ensuring no otters or other species, are in the vicinity of works before vehicular movement 05033 59687. This area contains the seaweed and there is a gradual increase in noise; species Fucus ceranoides, specific to areas of freshwater input.  Staff will remain vigilant for breeding birds and nests in the treelines immediately adjacent to the proposed works (up to 10m from the carriageway). Should evidence of nests or breeding birds be seen, works will stop and the site supervisor will be informed who will then seek advice from the BEAR Environment Team;

 Any excavations, entrances to pipes/drains or areas where an animal could be trapped will be covered over at the end of each shift and following completion of the works to avoid animals falling into them and becoming trapped;

 If lighting is required during the hours of darkness during the active season it be as focused as far as is possible on the works.

 Refer to and follow above mitigation regarding adherence to PPGs and GPPs.

Further mitigation measures to prevent materials from entering the marine environment are detailed in the Water section. Mitigation measures to prevent noise disturbance to terrestrial and marine species is outlined in the Noise section.

Landscape The scheme is located within the Ben Nevis and Glen During the construction phase, visual impacts are expected as a . Land required for building the compound area will be confined to the minimum require area; Coe National Scenic Areas (NSA). The landscape result of the erection of a temporary access platform and around the Ballachulish bridge is characterised by containment structure on the bridge. Due to the temporary nature . The site will be kept clean and tidy during and following maintenance works; rolling valleys including the Ben Nevis mountain and scale of the works not resulting in a permanent change to the . All waste will be removed from site, with a preference for recycling, otherwise disposal at a licensed waste Range. There are views of Loch Leven and Glen Coe local landscape character and adherence to the mitigation facility in compliance with Waste Management Regulations; and to the east and Loch Linnhe and the Garbh Bheimm measures and the SEMP, significant impacts on landscape are not peak to the West. anticipated during the construction and operational phases. . Vehicles and large machinery/equipment will be kept as clean as possible and switched off when not in use; . Land Land use to the south of the scheme is comprised Other than that required for building the site compound, no land mainly of forestry land and Dragon’s Tooth Golf take will occur and no change in land use is expected. No Course occupies a large section of land south-west of residential or commercial properties, community facilities or the scheme. There are a small number of residential agricultural land will be affected by the works and so the impact on and commercial properties within the vicinity of the land use is not anticipated to be significant during the construction scheme (refer to Air and Climate). and operational phases.

Land use to the north of the scheme is comprised of open grassland, forestry and a small number of commercial and residential properties (refer to Air and Climate). Noise Noise and vibrations levels in the vicinity of the There is a potential for disruption during the construction phase to . The owners and occupiers of the residential/commercial properties located within 200m of the Ballachulish scheme are predominantly influenced by the traffic the protected species identified in the Biodiversity section and The Bridge will be informed of the works at least 14 days in advance of the works; using the A87. Ballachulish Hotel due to its close-proximity to the proposed works. . All plant and machinery will be switched off when not in use; There are approximately eight residential properties Currently, the works are programmed to take place entirely during . The Being a Good Neighbour toolbox talk will be included in the Site Environmental Management Plan north-east of the scheme within 200m and five (SEMP) and delivered to site personnel prior to works; residential properties within 200m south of the daytime hours to reduce potential impacts from noise and 16 Transport Scotland Trunk Road and Bus Operations

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scheme. There is a small industrial estate with four vibration. If this changes, The Highland Council Environmental commercial properties north-east of the scheme . The Best Practicable Means, as defined in Section 72 of the Control of Pollution Act 1974, will be Health Officer will be consulted and this will be included as an employed at all times to reduce noise to a minimum; within 200m. Further detail is provided in the Air and addendum to the ROD. Climate section. . Night works are not expected to be required but this will depend on design requirements and the contractor’s programme and method of works. If required, the Highland Council Environmental Health With the implementation of mitigation measures, noise impacts are Officer will be consulted prior to the works; not anticipated to be significant during the construction phase. . All plant will be operated in a mode that minimises noise emissions and will have been maintained The proposed works are not anticipated to affect noise levels regularly to comply with relevant national and international legislation; during the operational phase as it will not result in a change in . traffic levels or dynamics. . Consultation will be carried out ahead of the works with affected residents to inform them of the proposals; . Residents will be provided with a 24-hour contact number within the consultation letter; . Temporary staff toilets/site compound will be located as far as is practicable from sensitive receptors; . If generators are required, these will be located as far away from residences as reasonably practicable.

Population and Human Health The scheme carries the National Cycle Network Traffic management will be implemented to alleviate disruption to . A Traffic Management Plan will be developed to minimise disruption to vehicle travellers; (NCN) Route 78 ‘The Caledonia Way’ which runs vehicle travellers throughout the construction periods. from Oban to Campletown. There is a stepped-up . Traffic will be controlled by temporary traffic lights, maintaining continuity of vehicle movement during the construction phase; pavement adjacent to each carriageway on the With the implementation of good practice and management bridge. measures, impacts on vehicle travellers are not anticipated to be . Motorists will be informed of works and likely delays via the Traffic Scotland website, media releases and significant. by variable message and fixed signs; Core path LO19.02 is located approximately 170m . The needs of NMU traffic will be considered within the design of the Traffic Management Plan; and east of the northern extent of the bridge. . NMU access between North and South Ballachulish will be maintained during and following the There are three bus stops in the vicinity of the NMUs using the Ballachulish Bridge are likely to be impacted maintenance works. scheme. The nearest bus stop is approximately 60m during the construction phase and whilst traffic management east of the southern extent of the bridge on the A828. measures are in place. With the implementation of good practice, Two additional stops are located on the A828 impacts on NMUs are not anticipated to be significant. adjacent to The Ballachulish Hotel, approximately 180m west of the southern extents of the scheme Core Path LO19.02 is not anticipated to be impacted during the proposed works.

The proposed works will no affect on the surrounding local population or human health during the operational phase as the works will not result in a change in access. This includes both NMUs and vehicle users. Water There are two waterbodies located within the vicinity There is potential for impacts on water quality as a result of the Waste water generated from hydro-demolition must be contained and either disposed of under a licence or of the scheme. Loch Leven is crossed by the scheme refurbishment works from potential discharge of silt, fuels, paint treated before being discharged into Loch Leven. Before any water can be discharged, the water parameters 2 and is a water body of 8.5km . Loch Linnhe (south) is fragments, soil and waterproofing chemicals into Loch Leven. must meet a pH requirement of between 4 – 10 and also a Suspended Solids limit of 100mg/l. Depending on a coastal waterbody of 149km2 and is located west of Hydro-demolition works will result in the production of large the amount of water discharged daily, a registration or simple licence under the Controlled Activities the scheme. amounts of solids in solution which is likely to be mildly alkaline. This would have potential to cause deterioration of habitats and Regulations (CAR) must be obtained from SEPA. The SEPA flood map indicates that there is a high have adverse impacts on aquatic species should this be Mitigation proposed with regards to the cyclical maintenance works are as follows: likelihood of coastal flooding in North Ballachulish. It discharged into Loch Leven. also indicates a Medium likelihood of coastal flooding . A marine licence will be secured and all conditions will be adhered to; on the A828 road which runs below the southern The grit blasting of the superstructure will result in significant approach to the bridge. quantites of paint fragments created which could cause negative . All SEPA Controlled Activities Regulations (CAR) licence will be obtained for all discharges into Loch impacts on the water quality if not contained by the containment Leven and the conditions of SEPA CAR licence will be complied with throughout the course of the works; structure around the bridge. The Bridge is not located wholly within a SEPA . Relevant Construction Industry Research and Information Association (CIRIA) guidance and SEPA’s surface water drinking area but there is a surface Waste water generated from hydro-demolition must be contained Pollution Prevention Guidelines (PPGs) and Guidance for Pollution Prevention (PPGs) will be followed drinking water protected area 400m south-west of the and either disposed of under a licence or treated before being scheme. is the scheme os located within a ground- including PPG 1, 6, 7, 8, 13, 18, 21 and 22. Particular attention will be paid to GPP 5: Works and discharged into Loch LevenWith the implementation of good maintenance in or near water, PPG 6: Working at construction and demolition sites and PPG 21: Pollution water drinking protected area. practice, management measures and mitigation, impacts on the incident response planning; water environment are not anticipated to be significant. The proposed works are not expected to affect water quality . In the event of a pollution incident occurring, SEPA and BEAR Environment Team will be notified within 24 during the operational phase since it will not result in a change in hours of the event; road drainage patterns or traffic levels. . A contingency plan will be put in place to minimise the risk from pollution incidents or accidental spillages and all necessary containment equipment will be available on site and staff trained in its use;

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. Sediment traps and sedimentation mats will be used where required during construction to prevent sediments and chemicals entering the water environment; . All re-fuelling will take place at a designated re-fuelling site, away from Loch Leven and any road drains within the area of works; . Oils, fuels and chemicals will be stored in bunded areas off the bridge at the best practice requirement of 110% of containment capacity of the volume stored. Drip trays will be used and maintained when dispensing; . Spill trays will be fitted to all stationary construction plants; . Waste will be stored in designated areas, isolated from surface water drains and any area that discharges into the water environment; . All skips will be covered or enclosed and waste materials will be removed from site by licenced waste carriers; . Works will be encapsulated in a double-skinned membrane to filter hydro-demolition water. Solid waste captured will be bagged and removed from site to a licenced landfill site by licenced waste carriers; . Containment will be in place for hydro-demolition and a sump pit will be used to catch run-off water; . Fresh concrete will be poured in such a manner that no concrete is lost or can enter the marine environment and debris netting will be installed around the area being broken out; . Gully cleaning vehicles are to be used which will vacuum water and debris from the gullies, and vacuum trucks will be emptied at licenced facilities; . Bird Guano will need to be double bagged to prevent spillage and will be taken to a licenced facility; . All milling works will be carried out during suitable periods of weather to ensure that waste material is not blown or washed in the water. . Debris netting is to be installed around the area being milled as required; and . Edge protection and debris netting to be installed to ensure materials can’t be knocked over the edge of the bridge during construction of the new parapet.

Soils and Geology There are no designated geological sites within the The works to the bridge will have no impact on geological . Mitigation detailed within the ‘Water’ section will minimise the risk of potential contamination of soils and study area. resources. geology through spillages.

Waste, Materials and Use of Natural Materials to be used for the maintenance programme With the implementation of mitigation, impacts relating to materials . The sub-contractor will adhere to waste management legislation and ensure they comply with their Duty of Resources will include but not be limited to: and waste are not anticipated to be significant. Care; Paint; . The sub-contractor will provide all information on quantities of waste (including recycled and re-used) and Replacement bearings; transportation of materials required by the Operating Company; Replacement expansion joints; New road surface; . All waste will be removed from site and disposed of safely and legally, preferably by recycling or re-use. Concrete; and Planings will be disposed of under a paragraph 13(a) exemption (as described in Schedule 3 of the Waste Replacement parapets. Management Licensing Regulations 1994): . All temporary traffic management equipment, including signs and cones, will be removed from site upon Waste material will include old paint flakes that have completion of the works: been grit-blasted off the structure, bird guano, and the redundant fixtures and fittings of the bridge that are to . Re-use and recycling of waste is encouraged and the sub-contractor will be required to fully outline their be replaced. plans and provide documentary evidence for waste arising from the works (e.g. waste carriers licence, transfer notes and waste exemption certificates) as well as filling in the sub-contractor’s waste return spreadsheet; and

. Mitigation measures regarding materials and waste are outlined in the Water section will be adhered to. Risk of Major During the construction phase, with the implementation of The scheme will not result in a change to the . The maintenance works are necessary to ensure the longevity of the bridge and operational reliability. Accidents or appropriate signage and traffic management, road users and Disasters alignment or width of the road. The maintenance works are necessary to ensure the longevity of the NMUs will be made aware of lane and footpath closures and the

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bridge and operational reliability. For example, presence of traffic lights. No significant impact on road safety is drainage clearing as part of the maintenance works expected during the construction phase. will ensure Ballachulish Bridge is more resilient to flooding. The proposed works are not anticipated to result in a greater risk of major accidents during operation as there is will be no change in traffic levels or alignment. Cumulative Effects At this time there are no other relevant developments The maintenance works on the Ballachulish Bridge are part of a . Mitigation detailed in the ROD and SEMP will be adhered to. proposed in the vicinity of Ballachulish Bridge. maintenance programme which includes improvements for five bridges in the North-West Unit.

Due to the short-term nature of the works, the absence of other bridge maintenance programmes within the vicinity of the Ballachulish Bridge and the appropriate mitigation listed herein and in the SEMP, cumulative impacts on receptors including the MPA and SAC are not considered to be significant.

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References

 Air Quality in Scotland (AQIS) (2018). National Air Quality checker. Available at: http://www.scottishairquality.co.uk/

 Scottish National Heritage (SNH) (2018). Sitelink: Designated site finder. Available at: http://gateway.snh.gov.uk/sitelink/searchmap.jsp

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APPENDIX A: SCHEME LOCATION AND EXTENTS

Figure A1: Location of scheme

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APPENDIX E: CONSULTATION

Summary of Consultation

Consultee Consultee Response Addressing Concerns SNH The engineers are confident that all Additional information to address uncertainties of the materials used and waste regarding the concrete repairs. generated can be completely contained and disposed of off-site. Marine license pre-application advice

Agreed that there will be no significant impacts on the special qualities of the Ben Nevis and Glen Coe NSA. SEPA Engineering activities in coastal and For the hydrodemolition works the contractor will use transitional waters are not regulated by freshwater (contained within a lorry) and spray the SEPA under CAR, but by Marine concrete, therefore there would be no abstraction Scotland. SEPA expect a robust required. The contractor will likely intend to discharge construction method statement. There this water in to the marine environment (adjacent to should be continuing supervision of the bridge). construction operations and ongoing review of the effectiveness of any A sump pit will catch run off water and then waste mitigation measures employed. concrete collected would be removed from the site.

Any abstraction for the purpose of concrete repairs to the bridge substructures do not require authorisation under CAR providing returned water does not cause pollution.

Any removed material that has no further use and is to be placed upon the shore, this material is considered a waste and will need to go to a site authorised to receive waste or one that is exempt from the waste regulations. It will also need to be transported with a transfer note and by a waste carrier.

WFRT WFRT had no further comment to provide on the scheme when consulted

Consultation with SEPA:

From: [Redacted Sent: 21 May 2018 15:05 To: [Redacted] Subject: FW: BEAR Bridges Maintenance Programme

I realise[Redactedis now out of the office until 30th May. In her absence I would be most grateful if someone could respond to my query below.

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From: [Redacted] Sent: 14 May 2018 10:18 To: [Redacted] Subject: [EXTERNAL] BEAR Bridges Maintenance Programme

The Water Environment (Controlled Activities) (Scotland) Regulations 2011 (as amended) The Waste Management Licensing (Scotland) Regulations 2011 (as amended)

Dear[Redacted]

Thank you for your time on the telephone last week to discuss the proposed bridge maintenance at A87 280 Carrich Bridge, A87 245 Dornie Bridge and A87 290 Skye Bridge. And apologies for my delay in response.

To confirm, engineering activities in coastal and transitional waters are not regulated by SEPA under CAR, but by Marine Scotland of which you have already sought consultation with. SEPA would however expect a robust construction method statement. The construction method statement should not however been seen as exhaustive and as work develops there may be additional site specific mitigation measures that require to be incorporated into working methods. There should additionally be continuing supervision of construction operations and ongoing review of the effectiveness of any mitigation measures employed.

Abstraction activities from coastal and transitional waters are CAR Regulated, however you do not require authorisation for the temporary abstraction of water to enable working within a river. River working within the ‘CAR A Practical Guide’ eludes to being more specific to inland surface water abstractions, we would in this particular case be content to take a local regulatory position that any abstraction for the purpose of concrete repairs to the bridge substructures do not require authorisation under CAR providing returned water does not cause pollution.

Please note that any removed material that has no further use and is to be placed upon the shore, this material is considered a waste and will need to go to a site authorised to receive waste or one that is exempt from the waste regulations. It will also need to be transported with a transfer note and by a waste carrier.

If you have any further queries, let me know.

Kind Regards, [Redacted]

[Redacted]

SEPA, Carr’s Corner, Lochybridge, Fort William, PH33 6TL [Redacted]

Consultation with SNH:

From: [Redacted] Sent: 06 April 2018 10:35 To: [Redacted] Cc: [Redacted]

Subject: RE: [EXTERNAL] RE: Marine Licence Applications for 5 year maintenance programme_BEAR Scotland

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[Redacted] thank you for consulting us requesting our pre application advice on the bridge maintenance work . Our opinion on these works is set out below.

Ballachulish Bridge 17NW1203/050 We agree with your conclusion that there will not be significant impacts on the special qualities of Ben Nevis and Glen Coe NSA.

Please let us know if there are any material changes to the works.

Regards

From: [Redacted] Sent: 29 March 2018 09:28 To: [Redacted] Subject: FW: [EXTERNAL] RE: Marine Licence Applications for 5 year maintenance programme_BEAR Scotland

Hi both

I have just received this reply from MS‐LOT. At this stage it would still be our intention to have two separate applications for Dornie. One MLA to cover scour repair and the other MLA to cover all remaining maintenance activities.

I look forward to hearing from you in due course.

Kind regards

[Redacted]

From: [Redacted] Sent: 29 March 2018 08:58 To: [Redacted] Subject: [EXTERNAL] RE: Marine Licence Applications for 5 year maintenance programme_BEAR Scotland

Hi [Redacted]

Thank you for taking my call yesterday, it was helpful to discuss the proposal.

I would suggest that a separate application is submitted for each of the bridges. The question regarding separate applications being submitted for scour repairs at Dornie and Connel, would be for the applicant to decide. If separate applications are submitted, the other on-going works should be considered in the application.

From my initial review of the documentation, I would not consider any of the works to require PAC.

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site by licensed waste carriers. 8. Fresh concrete will be poured in such a 8. Fresh concrete will be poured in such a manner that no concrete is lost or can manner that no concrete is lost or can enter the marine environment. enter the marine environment.

We can confirm that there is likely to be a combination of both hydrodemolition work and small repairs (using hand tools) required. It is assumed that the activity could take place both above and below the bridge.

Below the bridge

As a consequence of Health and Safety requirements – specifically working from heights and working near water – any work being carried out beneath the bridge will require an adequate working platform and railing to prevent any workers from falling. Around this platform and railing, containment will be achieved by the attachment of either debris netting (if small repairs only) or thickened sheets (if hydrodemolition). Furthermore, should hydrodemolition be required then the platform floor materials will be layered in such a way to prevent any material or water from going through the floor - for example at Cromarty Bridge - 1 x layer of Terram, 1 x layer of Visquine and finally an additional layer of Terram was used for the flooring (see attached picture).

The concrete fragments that land on the access system floor, during large or small repair works are then cleaned up, taken to the surface of the bridge and removed from site by licensed waste carriers. The water is pumped back up to the bridge deck, collected and removed from site by licensed waste carriers. If the intention is to discharge the water in to the environment a CAR licence will be obtained. At Cromarty Bridge water was pumped from the platform below, up to a ‘Siltbuster’ to be filtered and pH reduced before discharging into the environment (see attached picture).

As noted, there may be a requirement to access areas of the bridge that lie between MHWS and MLWS, specifically on the piers. This will be facilitated by either a fixed platform, that at certain states of the tide will be immersed or, more likely, and as done at Cromarty Bridge, by a platform that is raised/lowered accordingly (see attached picture). If a fixed platform is used then workers will ensure that all debris, material, work water is removed from the platform before immersion and then removed from the site by licensed waste carriers.

Above the bridge

Debris netting or sheeting will be applied around the working area to prevent materials and/or works water (hydrodemolition) from entering the marine environment. Material will be collected in the same manner as described above and removed from the site by licensed waste carriers or, in the case of water, potentially discharged into the marine environment if a CAR licence is obtained for this process.

I hope this provides the clarification you were seeking; however, please feel free to contact myself to discuss further if required.

Should there be any other clarifications in relation to the documents submitted last week, please don’t hesitate to contact me.

Kind regards [Redacted]

[Redacted]

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From: [Redacted] Sent: 22 March 2018 13:05 To: [Redacted] Cc: [Redacted] Subject: [EXTERNAL] Additional information regarding minor concrete repairs below MHWS on Skye, Carrick, Dornie and Ballachullish Bridges

[Redacted]

Thanks for your phone call. We discussed uncertainties regarding methodologies for the minor concrete repairs, and in particular work on sections of the bridge that are close to or below MHWS. The engineers are confident that all of the material used for, and generated by, such works can be completely contained and disposed of off- site. You are going back to the engineers to get detail on how this would be achieved and will send that on to Corrina for consideration as part of your earlier pre-app enquiry. You hope to get that to us by the end of this week.

[Redacted]

From: [Redacted] Sent: 16 March 2018 16:09 To: MS Marine Licensing Cc: [Redacted]

Subject: Marine Licence Applications for 5 year maintenance programme_BEAR Scotland

Dear Sir/Madam

Please find attached a covering letter and relevant supplementary documentation.

Should you have any queries, please feel free to contact me either by email or phone.

Regards

[Redacted]

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Dear Sir/Madam As part of a proposed bridge maintenance programme, BEAR Scotland, on behalf of Transport Scotland, intend to carry out maintenance and repair work at a number of bridges across Scotland. Jacobs UK Ltd, working on behalf of BEAR Scotland, have been commissioned to prepare and manage the Marine Licence Applications for five bridges:  A87 Carrich Bridge (approach to Skye Bridge)  A87 Skye Bridge  A87 Dornie Bridge  A82 Ballachulish Bridge  A828 Connel Bridge

It is intended that the proposed maintenance programmes for each of the five bridges are covered under separate 5-year Marine Licences. This will allow maintenance works to be carried out, when required, during this 5-year period. Therefore, in due course we will be submitting separate Marine Licence Applications, under the Marine Scotland (Act) 2010 Part 4, to cover the proposed maintenance programmes for each of the bridges listed above. A summary of the maintenance works for each bridge is provided within the table below. A detailed description of all the proposed maintenance works for each bridge, including mitigation measures, is provided in the attached documents. We would welcome any comments from MS-LOT on the intended approach, specifically if MS-LOT could advise whether additional, and therefore, separate Marine Licence Applications, would be required (or advised) at Dornie Bridge and/or Connel Bridge to cover the subtidal scour repair activity. To assist MS-LOT in this regard, we have provided detail on the works and designated sites in the vicinity of each bridge. The proposed maintenance activities are broken down to ‘scheme’ and ‘cyclic maintenance’ works. Scheme represents those works that will be required over the next 5 years, whilst cyclic represents those works which may be required over the same timeframe. All the bridge maintenance programmes require a limited degree of works to be carried out within the intertidal (between MHWS and MLWS) and/or underneath the bridge. Of the five bridge maintenance programmes, only the proposed scour repair at Dornie Bridge and Connel Bridge will require work below MLWS, in the subtidal environment. Jacobs will be carrying out a site walkover and otter survey at each bridge which will contribute towards a Site Investigation Note. An Environmental Screening Report and Site Environmental Management Plan for each site will also be produced in due course. These activities will assist in understanding whether EPS licences will be required at each site, with further consultation being sought in the near future once more information is available. However, recognising the localised and minimal scope of the proposed maintenance activities, we have made some early assumptions regarding the potential to effect designated sites within the vicinity of the bridges. As Transport Scotland (TS) are the competent authority for roads projects, if it is deemed that there would be a likely significant effect on any of the qualifying interests at the bridges then TS will carry out their own Appropriate Assessment.

Ballachulish Bridge It is unlikely that the proposal would have any significant effect (direct or indirect) on the qualifying features of the Onich to North Ballachulish woods SAC (woods, forests and otter) or Glen Etive and Glen Fyne SPA (golden eagle). It is unlikely that the proposal would have any significant effect (direct or indirect) on the features of St Johns Church SSSI (geology) or Onich to North Ballachulish woods SSSI (woodlands, upland habitats and geology). The proposed works would not affect the important views of the Ben Nevis and Glen Coe National Scenic Area (NSA).

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Appendix G: BEAR 5YRMLA SUPPORTING INFORMATION, BALLACHULISH BRIDGE

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